Action Plan Development

1

A CDBG disaster recovery grantee must:

Step 1: Determine the effects of the disaster

Step 2: Develop a plan to respond to the

most critical disaster recovery needs not

addressed by other resources

Step 3: Implement the plan; ensure activities

are completed in an efficient & timely

manner

The “big picture”

2

Address Step 1 (effects of disaster)

Address Step 2 (plan development)

Goals of this Presentation

3

A beach house struck by Hurricane Sandy Bayville, New Jersey

The Disaster Relief Appropriations Act, 2013

(Pub. L. 113–2, approved January 29, 2013)

The Department’s Federal Register Notice–

78 FR 14329 (published March 5, 2013)

The Action Plan Checklist– a guide to assist

grantees and Action Plan reviewers

References / Useful Tool

4

Step 1: Assess recovery

needs post-disaster

5

An evaluation of disaster-related impacts

on a state, city, and community

At a minimum, must evaluate three core

aspects of recovery:

housing

infrastructure

the economy

Needs assessment

6

Housing Evaluate the needs for interim and permanent, owner

and rental, single family and multifamily, affordable and market rate, including public and HUD-assisted housing and housing for the homeless

Infrastructure Evaluate the needs for restoration of roads, bridges, or

other public structures

Economy Evaluate estimated job losses or revenue loss

Needs assessment

7

Also take into account other assistance

available, or likely to be available, for

affected communities and individuals E.g., FEMA funds available for public infrastructure, or

insurance funds available for homeowner rehabilitation

Why? Disaster recovery resources are

scarce; ensure CDBG disaster recovery

funds meet critical, unaddressed needs

Needs assessment

8

Use the best available data to:

Identify & document needs

Allocate CDBG disaster recovery funds

Illustrate the connection between the recovery needs and the allocation of funds

Purpose

9

Disaster recovery needs evolve over time,

the needs assessment (and Action Plan)

may need to be updated periodically

Contact FEMA/SBA for additional unmet

housing and business needs data

Evolving Recovery Needs

10

Step 2: Develop a

CDBG Disaster Recovery

Action Plan

11

Using needs assessment, ascertain what types

of activities or programs will best address the

grantee’s (unmet) recovery needs

Get as much input as possible– reach out to

affected communities and citizens

Talk to existing grantees– what worked well in

other communities? What didn’t work so well?

Research

12

All activities must clearly address an impact

and show a tie to the disaster

Each activity must:

be CDBG eligible (or receive a waiver),

meet a national objective, and

address a direct or indirect impact from the

disaster in a Presidentially-declared county

identified in the Notice

Allowable activities

13

105(a) of the Housing & Community Development Act

(HCDA) of 1974 http://portal.hud.gov/hudportal/HUD?src=/program_offices/comm_planning/co

mmunitydevelopment/rulesandregs/laws/sec5305#sec5305(a)

Guide to National Objectives and Eligible Activities for

State CDBG Programs http://portal.hud.gov/hudportal/HUD?src=/program_offices/comm_planning/co

mmunitydevelopment/library/stateguide

Guide to National Objectives and Eligible Activities for

Entitlement Communities http://portal.hud.gov/hudportal/HUD?src=/program_offices/comm_planning/co

mmunitydevelopment/library/deskguid

Eligible CDBG activities– links

14

The grantee must document that each eligible

activity meets a national objective–

Benefits low- and moderate-income persons, or

Addresses an urgent need, or

Aids in the prevention or elimination of slums or blight

For an in-depth discussion of national

objective, see the Guide to National

Objectives and Eligible Activities

National Objective

15

The grantee must also demonstrate how each

activity and program is tied to the disaster

Both the Action Plan and individual activity files

should document the connection

Tie to the disaster

16

A residence badly damaged by Hurricane Sandy Leonardo, New Jersey

Local government grantees carry out

activities directly

State grantees must determine whether to:

Use a method of distribution, or

Carry out activities directly, or

Use a combination of the above

Ways to distribute funds

17

State grantees may award funds to local

governments based on damage estimates

i.e., could use a method to distribute funds for an

infrastructure or housing project or activity

May use a method of distribution for all funds,

but should ensure that method will adequately

address needs identified by the assessment

Method of distribution

18

Pros

Quickly get funds to local governments

Local governments have flexibility to determine most

critical needs

Cons

Strictly competitive method may lack a clear

connection between activities and recovery needs

Requires significant oversight to ensure funds comply

with applicable state and Federal laws, regulations,

and Federal Register notices

Method of distribution

19

Grantees (including states) can design and carry

out activities directly

Typically, this means the grantee develops the

activity/program, reviews submitted applications,

monitors applicants, etc.

Can use a subrecipient or procure a contractor, but

grantee remains responsible for inherently

governmental responsibilities related to

management of the funds (e.g., oversight, policy

development, and financial management)

Direct implementation

20

Pros

Able to develop and implement specific activities/

programs that are narrowly tailored to meet identified

recovery needs

More oversight of CDBG disaster recovery funds– less risk

of fraud, abuse, or waste

Cons

Significant capacity needed to design and implement

programs directly; may delay initial expenditures and

could increase administration expenses if not properly

executed

Direct implementation

21

State grantees may design an activity/

program (or several) and use a method of

distribution to award funds to units of local

government

E.g., Ohio designs an economic development

program; uses a method of distribution to

award funds to eligible local governments

Combination

22

Pros

Able to develop and implement specific activities/

programs that are narrowly tailored to meet

identified recovery needs

Units of local government are responsible for day-to-

day administration of specific recovery activities

Cons

May be a disconnect between the state and the units

of local government if they fail to maintain open and

continuous communication

Combination

23

Prior to formal submission to HUD, the grantee

must post the Action Plan for public comment

for a minimum of 7 days

Action Plan submitted to HUD must address all

comments received through the public comment

period

Citizen participation

24

Once the published Action Plan is accepted

by HUD, the grantee may enter information

from the plan into the Disaster Recovery and

Grant Reporting System (DRGR)

HUD will review the DRGR Action Plan; when

approved, funds will be made available for

use

DRGR Action Plan

25

Key difference between published Action Plan and

DRGR Action Plan:

Published plan provides detailed information

regarding the needs assessment, general

requirements applicable to the CDBG disaster

recovery award, and rules for each program

developed by the grantee

DRGR plan provides greater specificity for measuring

performance of individual activities

DRGR Action Plan

26

Each activity must identify “start” and “end”

dates

Although standard CDBG timeliness requirements are

waived (24 CFR 570.494 and 570.902), grantees

must still ensure activities are completed in

accordance with their performance measures

The Appropriations Act requires grantees to expend

funds within 2 years of the date HUD signs a grant

agreement with the grantee

DRGR Action Plan

27

The Action Plan must be updated to include the

grantee’s expected performance (i.e., expenditures

and outcomes) each quarter

The Action Plan must also include a projected

expenditure schedule for the entire grant

Guidance is available on the CDBG Disaster

Recovery website

Performance Schedule

28

Each grantee receiving an allocation under

the Notice must submit an Action Plan within

90 days of the effective date of the Notice

Action Plan submission

29

Section 104(e)(1) of the HCDA requires HUD

to determine whether the grantee has carried

out its activities in a timely manner

The Department will, absent substantial

evidence to the contrary, deem a grantee to

be carrying out its programs and activities in

a timely manner if its performance schedule is

substantially met

Timeliness

30

CDBG Disaster Recovery website: http://www.hud.gov/offices/cpd/communitydevelopment/

programs/drsi/index.cfm

Includes:

Supplemental appropriations laws

Federal Register notices

Contact information, Action Plans and Quarterly Performance Reports for CDBG disaster recovery grantees

Peer CDBG-DR grantees

Your HUD CPD representative

Resources

31

Questions?

32